SC Disbars Prosecutor For Maligning Justices, Bar Confidant: September 7, 2023

SC Disbars Prosecutor for
Maligning Justices, Bar Confidant

September 7, 2023
FACTS:
• The disbarment arose from a complaint against then Atty. Ramirez filed in 2007
by Aurora R. Ladim, Angelito A. Ardiente, and Danilo S. Dela Cruz, employees of
Lirio Apartments Condominium in Makati City where Ramirez resided. They
sought the disbarment of Ramirez for her unruly and offensive behavior towards
residents and employees of the condominium, which stemmed from various
incidents from 1990 to 2007.
• In a Resolution dated July 30, 2014, the Court found Ramirez liable for violation of
Canon 7.03 of the CPR, which prohibits lawyers from engaging in conduct that
adversely reflects on their fitness to practice law and from behaving in a
scandalous manner, whether in public or private life. Ramirez was suspended
from the practice of law for six months, with a stern warning that a repetition of
the same or similar acts shall be dealt with more severely.
FACTS:
• When Ramirez requested for the lifting of her suspension in 2016, the Office of
the Bar Confidant (OBC), through then Bar Confidant Atty. Ma. Cristina B. Layusa,
advised Ramirez to file the necessary motion and submit a sworn statement that
she did not practice law during the period of her suspension. But Ramirez
questioned the Bar Confidant’s authority and claimed that such requirements did
not apply to her.
• Because of Ramirez’s refusal to file the required sworn statement to prove that
she did not practice law during her suspension, the OBC recommended that her
request be denied. This recommendation was adopted by the Court in its August
1, 2016 Resolution denying her prayer to lift her suspension, until she has
complied with the submission of the required sworn statement and the necessary
certifications from the Integrated Bar of the Philippines and the trial courts.
FACTS:
• On March 15, 2017, Ramirez went to the OBC to follow-up on the status of her
request on the lifting of her suspension order. After Atty. Layusa explained to
Ramirez the dispositive portion of the August 1, 2016 Resolution, the latter
started berating Atty. Layusa: “BRUHA KA; OO, BRUHA KA; PUTANG INA MO; YOU
ARE A DISGRACE TO THE LEGAL PROFESSION; KONTING BRAINS NAMAN;
CLERK KA LANG; YOU DON[‘T] KNOW YOUR WORK; YOU DON[‘T] KNOW YOUR
JOB; xxx.”
• Ramirez also made foul and offensive remarks to the Justices of the Court: “ARE
THOSE JUSTICES PASSERS UNDER R.A. 1080 [?]”
• Ramirez’s outbursts right inside the OBC were witnessed by OBC personnel and a
member of the Supreme Court Security Division.
FACTS:
• The Court, in a Resolution dated April 19, 2017, required Ramirez to comment on
the Incident Report submitted by the OBC, but she failed to comply. When the
Court reiterated its order for Ramirez to file her comment, she submitted instead
a letter requesting for the lifting of her suspension. The Court then referred the
case to the OBC, which recommended that Ramirez’s request for lifting of
suspension order be denied, and that she be disbarred.
ISSUE:
• Whether or not Atty Ramirez violated Canon 7, Canon 8, and Canon
11 of the CPRA law?
RULING:
• In ruling on Ramirez’s case, the Court adopted the OBC’s recommendation,
stressing that “the practice of law is not a right, but a mere privilege which is
subject to the inherent regulatory power of this Court.”
• The Court underscored the canons governing the lawyers’ conduct towards the
legal profession, among which are Canon 7, which states that a lawyer shall at all
times uphold the integrity and the dignity of the legal profession and support the
activities of the Integrated Bar; Canon 8, which states that a lawyer shall conduct
oneself with courtesy, fairness and candor towards one’s professional colleagues,
and shall avoid harassing tactics against opposing counsel; and Canon 11, which
states that a lawyer shall observe and maintain the respect due to the courts and
to judicial officers and should insist on similar conduct by others.
RULING:
• Thus, “It is imperative for lawyers to ‘observe the highest degree of morality and
integrity not only upon admission to the Bar, but also throughout their career in order
to safeguard the reputation of the legal profession,”. The Court added that “lawyers
should always guard their language because any careless remark can ‘promote distrust
in the administration of justice, undermine the people’s confidence in the legal
profession, and erode public respect for it.”
• In the case of Ramirez, the Court found that her actions warrant the ultimate penalty
of disbarment based on several grounds. First, she brazenly insulted the Bar Confidant,
an official of the Court, right within the confines of the Supreme Court. The Court
stressed that maligning the Bar Confidant is not only an ad hominem attack on the Bar
Confidant’s person, but an affront to the Supreme Court as an institution which
Ramirez vowed to honor and respect. In addition, Ramirez also made disparaging
remarks against the Supreme Court Justices during her outburst at the OBC.
RULING:
• Second, Ramirez ignored the resolutions of the Court, refusing to confirm or deny
the charges against her, despite the Court giving her two opportunities to do so.
Neither was there any manifestation of apology or remorse from Ramirez since the
incident.
• Finally, the Court also considered that this was not Ramirez’s first offense, having
been previously suspended for violation of the CPR.
• “Unabashed, Atty. Ramirez maligned not only officers of this Court but the Court
itself as an institution with her erratic outburst in the confines of this office.
Evidently, Atty. Ramirez had shown a penchant for being arrogant and disrespectful
in her dealings, whether in her private or professional life, pompously using her title
‘Atty.’ as a license to belittle and mock others who do not follow her suit. To the
mind of this Court, her actions do not merit judicial empathy,” said the Court.
RULING:
• The Court also stressed the purpose of disbarment as a penalty: “[it] is not to
punish the individual Attorney himself or herself, but rather ‘to safeguard the
administration of justice by protecting the Court and the public from the
misconduct of officers of the Court.’”
• The Court added that disbarment is intended to cleanse the ranks of the legal
profession of its undesirable members, “especially those who have disregarded
their oath and have proved to be unfit to continue discharging the trust reposed
in them as members of the bar, just like Ramirez in this case.”

SC Disbars Prosecutor For Maligning Justices, Bar Confidant: September 7, 2023

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